Tools · For investors

Opportunity Zone basis step-up and 10-year rule calculator

Updated · Free, no sign-up, runs in your browser

A QOF investment has two separate tax benefits: a step-up that reduces how much of the deferred gain is taxed when it's included, and, after 10 years, an election that excludes the investment's appreciation (IRC §1400Z-2(b)-(c)). Which version you get depends on when you invest (P.L. 119-21, §70421(c)(5)(A)). This calculator follows one investment through both.

Related: January 1, 2027 deadline planner · OZ 2.0 tax calculator (compares a 1031 exchange and paying tax now) · Form 8997 tracker · 1031 exchange vs opportunity zone guide

Your investment
Result · OZ 2.0 rules (invested after Dec 31, 2026)
Appreciation excluded by the 10-year rule
$395,424
Tax not paid on that growth: $94,111. Sale assumed Feb 1, 2037.
Deferred gain included: $450,000 on Feb 1, 2032, tax $107,100 due Apr 15, 2033.
Your timeline
  1. Feb 1, 2027
    Invest $500,000
    No tax today
  2. Feb 1, 2032
    Gain included
    $107,100 tax
  3. Feb 1, 2037
    Sale
    $395,424 excluded
Basis step-up
$50,000
10% × $500,000; saves $11,900 of tax.
Gain included
$450,000
Tax $107,100, due Apr 15, 2033.
Value at sale
$895,424
10 years at 6%; basis before election $500,000.
Taxable gain at sale
$0
Tax $0.
Compared with paying the tax now
Same growth either way; nominal dollars, federal tax only.
Pay tax now
$610,600
Pay $119,000 now, invest the rest, pay $71,712 at sale.
Invest in the QOF
$788,324
Value at sale minus both taxes.
+$177,723
more after tax with the QOF than paying the tax now.

How this was calculated

  1. Value at year t = $500,000 × (1 + 6%)^t. At inclusion it's $669,113.
  2. Amount included = lesser of the deferred gain ($500,000) or that value, minus your basis (the $50,000 step-up): $500,000 − $50,000 = $450,000. Tax: × 23.8% = $107,100.
  3. Your basis then rises by the gain included: $50,000 + $450,000 = $500,000.
  4. Sold within 30 years with the election, basis = value at sale, so the $395,424 of appreciation is excluded.
  5. Comparison: $500,000 − $119,000 tax now, grown 10 years, minus 23.8% tax on the growth = $610,600. Amounts are nominal: no discounting, and the QOF line assumes you pay the inclusion tax from other money.

Estimates only; not tax advice. Federal tax only, at rates you enter (for example 20% + 3.8% NIIT = 23.8%); ignores state tax, fund-level income and fees, and future rate changes. Your inputs stay in your browser.

The rules, with sources

StepOZ 1.0: invested on or before Dec 31, 2026OZ 2.0: invested after Dec 31, 2026
Inclusion dateEarlier of a sale or Dec 31, 2026 (§1400Z-2(b)(1), text in effect for these investments; Treas. Reg. §1.1400Z2(b)-1(b))Earlier of a sale or 5 years after the investment (§70421(c)(2), new §1400Z-2(b)(1))
Starting basisZero, plus any step-up (§1400Z-2(b)(2)(B)(i), same in both versions)
Step-up+10% of deferred gain at 5 years, +5% more at 7 years (§1400Z-2(b)(2)(B)(iii)-(iv)); only reachable by Dec 31, 2026 for investments made by 2021 (5 years) or 2019 (7 years)+10% at 5 years, +30% for a qualified rural opportunity fund, treated as occurring before the 5-year inclusion date (new §1400Z-2(b)(2)(B)(iii)(I)-(II); rural fund defined in (b)(2)(C))
Amount included(Lesser of the deferred gain or the investment's fair market value on the inclusion date) minus basis (§1400Z-2(b)(2)(A); Treas. Reg. §1.1400Z2(b)-1(e)(3) for Dec 31, 2026). Basis then rises by the gain included (§1400Z-2(b)(2)(B)(ii)).
10-year exclusionHeld 10+ years and elect: basis = fair market value on the date of sale (§1400Z-2(c)). The regulation's protection after zones expire doesn't apply to sales after Dec 31, 2047 (Treas. Reg. §1.1400Z2(c)-1(c))Held 10+ years and elect: basis = fair market value at sale if sold before the 30-year date; otherwise fair market value on the 30-year date (§70421(c)(3), new §1400Z-2(c)(A)-(B))

The statute's OZ 2.0 step-up text: "In the case of any investment held for at least 5 years, the basis of such investment shall be increased by an amount equal to 10 percent (30 percent in the case of any investment in a qualified rural opportunity fund) of the amount of gain deferred" (P.L. 119-21, §70421(c)(2)).

Worked examples

All use a $500,000 deferred long-term gain, 6% annual growth and 23.8% federal rates (20% under IRC §1(h)(1)(D) plus 3.8% NIIT under §1411).

1. OZ 2.0, invested February 1, 2027, held 10 years

  • Inclusion February 1, 2032: the investment is worth $500,000 × 1.06⁵ = $669,113, so the full $500,000 counts; minus the 10% step-up ($50,000) = $450,000 included, $107,100 tax, due April 15, 2033. The step-up saves $11,900.
  • Basis is now $50,000 + $450,000 = $500,000. At sale on February 1, 2037 the investment is worth $500,000 × 1.06¹⁰ = $895,424. With the election, the $395,424 of appreciation is excluded (about $94,111 of tax not paid).
  • After both taxes: $895,424 − $107,100 = $788,324. Paying $119,000 now and investing $381,000 at 6% gives $682,313 before tax and $610,600 after 23.8% on the growth, so the QOF comes out about $177,723 ahead (nominal, no discounting).
  • In a qualified rural fund, the 30% step-up means $350,000 is included and $83,300 is due.

2. OZ 1.0, invested November 1, 2026, held 10 years

The full $500,000 is included on December 31, 2026, with no step-up, so $119,000 is due with the 2026 return on April 15, 2027. The sale on November 1, 2036 is before December 31, 2047, so with the election the same $395,424 of appreciation is excluded. After-tax value: $895,424 − $119,000 = $776,424.

3. OZ 2.0, held only 7 years

Inclusion and step-up are the same as example 1, but with no 10-year election the growth is taxed: $500,000 × 1.06⁷ = $751,815, minus the $500,000 basis = $251,815 taxable at sale ($59,932 tax).

FAQ

How much is the Opportunity Zone basis step-up?

For amounts invested after December 31, 2026 (OZ 2.0), basis rises by 10% of the deferred gain after 5 years, or 30% in a qualified rural opportunity fund, and the increase is treated as occurring before the 5-year inclusion date (IRC §1400Z-2(b)(2)(B)(iii), as amended by P.L. 119-21 §70421(c)(2)). For OZ 1.0 investments the step-ups were 10% after 5 years and 5% more after 7 years, but only holding time before December 31, 2026 counts, so an investment made after 2021 gets no step-up. Not tax advice.

What does the 10-year exclusion do?

If you hold the QOF investment at least 10 years and elect, your basis becomes its fair market value on the date you sell, so appreciation isn't taxed (IRC §1400Z-2(c)). The deferred gain itself is still taxed at the inclusion date; the exclusion covers growth on top.

Is there a time limit on the 10-year exclusion?

For OZ 2.0 investments, if you sell within 30 years, basis is fair market value at sale; otherwise it's fair market value on the date 30 years after the investment, so later growth is taxed (§1400Z-2(c)(A)-(B), P.L. 119-21 §70421(c)(3)). For OZ 1.0 investments, the regulation that keeps the election available after zone designations expire does not apply to sales after December 31, 2047 (Treas. Reg. §1.1400Z2(c)-1(c)).

What if the investment loses value before the inclusion date?

You include only the lesser of the deferred gain or the investment's fair market value on the inclusion date, minus your basis (§1400Z-2(b)(2)(A); Treas. Reg. §1.1400Z2(b)-1(e)(3) for the December 31, 2026 inclusion). The calculator applies that limit using the growth rate you enter.

Who qualifies for the 30% rural step-up?

Investors in a qualified rural opportunity fund: a QOF holding at least 90% of its assets in QOZ property used in, or QOZ businesses operating in, zones comprised entirely of a rural area (§1400Z-2(b)(2)(C)(i)). It applies only to amounts invested after December 31, 2026 (P.L. 119-21 §70421(c)(5)(A); Rev. Proc. 2026-14 section 2.01(4)(a)(ii)).